By Client Request: Breaking Down Task List Management

Managing your task list doesn't have to be tedious or daunting. At EWN, we are committed to providing clients and the industry with the most intuitive information you can use to manage task lists more effectively.

We recently met with Operators across the industry and found several common challenges they're facing regarding task list management. In this article, we will cover some of these issues plus our solutions and recommendations on how to help manage tasks lists.

1. Outdated Task Lists

One of the most common things we found among operators was outdated task lists. Here is the scenario:

You have been promoted to manage the company's OQ (Operator Qualifications) Program. The company's task list was created by one, two, or even three of your predecessors. The task list has not been touched in several years, and you choose not to make any additional changes. After all, whomever created the task list must have known what they were doing, and since it has worked all this time, why change it?

What we found was that new personnel charged with managing the OQ Program were never properly trained on how to manage the existing program or were not informed of changes and decision made to develop the existing program. In other cases, the answer was simply that it had always been done that way.

It is absolutely okay and necessary to make changes to your OQ Program and update your company's task list. Are you aware that 49 CFR 192.605(a) and 195.402(a) requires that each Operator prepares a manual of written procedures for conducting operations and maintenance activities, and that this manual must be reviewed and updated by the Operator at intervals not exceeding 15 months, but at least once each calendar year? By extension, if you modify your O&M (Operations and Maintenance) manuals, you'll also need to review and update your OQ Plan, task list, and associated methods of qualifications for the same period of time to reflect any changes in your programs or operations.

2. Inconsistency Throughout OQ Procedures

Another common issue we found between operators across the nation was inconsistency throughout their OQ procedures. For example, covered tasks within an Operator's task list did not align with what they had in their OQ and O&M plans, and/or their Standard Operating Procedures (SOP).

While managing a task list can seem intimidating because there are so many moving parts, it can be done. Start with understanding your responsibility for your company's OQ Program. It is the responsibility of the Operator to identify covered tasks, the requalification intervals, span-of-control ratios, and evaluation methods. This is what is required by 49 CFR 192 Subpart N and 49 CFR 195 Subpart G.

By law, the OQ Rule covers all the Operator's workforce including employees, contractors, and sub-contractors. So, contractors do not differ from employees when it comes to the regulations. Therefore, you need to include these tasks in your task list even if they are performed by a contractor. Also, be sure to clearly state in your O&M plan, OQ Plan, and SOPs that these tasks are being performed by a contractor. Consistency is crucial.

We recommend that you identify covered tasks for each facility and uniquely label them gas or liquid. Confirm that each task includes task-specific abnormal operating conditions and that they meet the requirements for each facility type.

3. Failure to Vet Third-Party OQ Programs

An additional issue among Operators involves a failure to fully vet 3rd Party OQ Programs to ensure the programs align with their company's operations. While it is acceptable to use a 3rd Party OQ Program or adopt an industry standard such as the ASME B31Q or a recommended practice such as the API 1161, the Operator will still need to review it prior to implementation.

You should not assume that you are compliant once you purchase a 3rd Party OQ Program or implement an industry standard or best practice. While this option can certainly help you get off to a great start, the Operator is still responsible for reviewing each task, evaluation methods, requalification intervals, etc., within the program.

Making significant changes to your task list also requires Operators to notify their state agency of the changes. According to PHMSA, a "significant change includes but is not limited to: increasing evaluation intervals, increasing span of control ratios, eliminating covered tasks, mergers and/or acquisition changes, evaluation method changes such as written vs. observation, and wholesale changes made to OQ plan."

There are many variables and examples that we can explore when it comes to managing your task lists. We would appreciate the opportunity to talk to you more about this topic, so please do not hesitate to give us a call or send us an email.